UPDATED COMMENTS ON DRAFT PERMIT TO INSTALL AND OPERATE
RIDGE ROAD INCINERATORS (P0107767)
Claude Lawrence Cornett, Jr.
Cornett Environmental Consulting, 2450 W. 6 St, Cleveland, OH 44113-4527
email@example.com (216)583-0007 6/13/2013
I am an environmental engineer with many years of experience with incineration and gasification systems and their potential and actual impacts through my work for the US DOE, the US EPA, private utilities, and a German municipal waste fired power plant manufacturer <http://cornettenv.org/resume.htm>. This work included engineering evaluations, emission estimates, risk assessment, monitoring, regulatory development, permits, health and safety, emergency response, and environmental remediation. I also designed, specified, and operated incinerators and associated equipment.
I briefly reviewed the revised draft permit to install and operate the proposed municipal waste incineration installation at Ridge Road in Cleveland, along with the associated application and related documentation. I immediately noticed that it is very similar to the previous draft permit that I commented on in February 2012 and was generally unresponsive to the comments and recommendations that US EPA, others, and I submitted.
The major changes from the previous draft permit that I noticed were that the new draft permit:
* Is called a draft permit to install and operate instead of a draft permit to install,
* Had three instead of four solid waste thermal processing lines with significantly reduced potential NOx emissions, obviously for the purpose of reducing its capacity to prevent US EPA from having regulatory authority to enforce its comments and recommendations on the proposed permit and to avoid OEPA Title V, MACT, PSD and major stationary source requirements,
* Allows higher annual dioxin emissions and slightly higher annual particulate, SO2, VOC, and Cd emissions from the proposed installation than the previous OEPA draft permit, while significantly reducing the allowable NOx, Hg, and Pb emissions.
* Allows higher annual emissions than were in CPPs Red-Line Strike-Out of the previous draft permit that was submitted with CPPs updated air permit application,
* Allows slightly higher carbon dioxide emissions, meaning that the proposed installation would be allowed to thermally process more combustible municipal waste than was allowed in the previous draft permit.
The proposed installation also has stacks which are 25’ taller to reduce maximum downwind concentrations while spreading the pollution further into the surrounding areas. The facility profile report also shows a 90% capture efficiency for filterable primary particulate matter emissions. Much higher capture and collection efficiencies are readily possible with properly designed and maintained equipment.
My previously submitted comments still apply to the draft permit, and I wholeheartedly endorse those submitted by the US EPA on February 23, 2012. Please consider those comments in detail and act accordingly. The US EPA comments and recommendations included:
* Regulating the installation as a municipal incinerator,
* The use of baghouse leak detectors,
* Using measurements rather than emission factors or unspecified methods to determine emissions,
* Considering background concentrations when evaluating its impacts on air quality, soils, vegetation, etc. along with the need for prevention of deterioration of ambient air quality and related regulations,
* Installing and maintaining better pollution controls and work practices than those described in the draft permit.
In addition, I am concerned about:
* The higher proposed utilization of the proposed installation than the previous proposal due to the reduction in the proposed number of waste treatment lines and its implications on the availability of the equipment for maintenance and repair, and on the reliability and real capacity of the proposed installation,
* The fact that the draft permit is for Kinsei Sangyo or equivalent batch “gasifiers," despite the fact that the patents for the proposed Kinsei Sangyo technology <http://www.patentmaps.com/assignee/Kinsei_Sangyo_1.html> clearly identify the technology as incineration and it is considered to be incineration by US EPA. Decision makers and the public were misled by calling the proposed Ridge Road thermal waste treatment process gasification while denying that it is incineration with energy recovery,
* The fact that some of what comes from the so-called batch gasifiers will be in the form of tar and other sticky aerosols to be burned in the furnaces. Has OEPA or CPP even read the patents for the Kinsei Sangyo technology and thought about this issue? Several patents characterize the proposed process as incineration by dry distillation and gasification. I previously submitted technical documents identifying the chemical composition of the expected aerosols, etc. The tar and sticky aerosols can also be demonstrated by putting some of your garbage in a pot on the stove with a partially closed lid, heating it continuously on high, and observing what is emitted and deposited in your kitchen. Such materials can coat, clog, and freeze portions of the complex network of valves and other equipment in the proposed installation, causing process failures and a danger of catastrophic accidents. The proposed process has many more valves and is much more complicated than other applicable technologies and has never been shown to work on American municipal waste.
* The fact that the permit specifies equivalent batch thermal treatment and energy recovery processes and does not include continuous processes that are simpler, proven for handling municipal waste, and which are likely to be more reliable, stable, and cost effective. If municipal waste is to be burned, at least it should be with a proven, reliable and cost effective energy recovery technology, and then only in a responsible manner and as a last resort.
* CPP fired the contractor proposing the Kinsei Sangyo technology for grossly misleading financial cost estimates and incompetence,
* The contractor would collect almost half a million dollars if the permit is granted or if CPP withdraws the application (unless the city challenges such payment based on them misleading the city and does the right thing by suing them).
I am very concerned about issuing such a permit for Kinsei Sangyo technology and about what constitutes an equivalent installation under the proposed permit:
* Could it be provided by an organization that misinformed the City of Cleveland and OEPA like Kinsei Sangyo through Princeton Environmental?
* Could it have no credible data to back up its estimates of many toxic air contaminant emissions or even that it would be capable of reliably and safely processing local municipal waste and generating electricity, as is the case with the proposed Kinsei Sangyo installation?
And more importantly:
* Does the Cleveland Division of Air Quality and Ohio EPA lack the technical expertise, motivation, professional standards, and/or authority <http://codes.ohio.gov/oac/3745-27-50> to require that a permit application for major installation of this nature include enough technical details for an engineering review to assure that the proposed installation would actually work properly, comply with regulations, and not pose an unreasonable risk to public health, welfare, and the environment before issuing a permit to install?
* Are permits to install merely statements of minimal requirements to comply with the least restrictive interpretation of the regulations that are most obviously applicable based on whatever is submitted with a permit application, regardless of the credibility of the applicant, the likelihood or unlikelihood that the proposed installation comply, and the danger posed to the public health, welfare and environment from any operations of the system prior to the emission testing required to obtain a permit to operate?
* Is the submission of unsubstantiated allegations of expected emissions and vague block diagrams and filling out the forms for a permit application sufficient to obtain a permit to install and test an unproven technology?
* Were the previously submitted comments on the previous draft permit seriously considered before issuing the draft permit; and, if so, where are the details of the OEPA analysis and response to those comments?
Under the circumstances, I strongly recommend that OEPA demonstrate that it is a professional and responsible environmental protection agency by rejecting the proposed permit and associated application.